Novas considerações sobre restituição do ICMS-ST

Novas considerações sobre restituição do ICMS-ST

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Por José Eduardo Tellini Toledo

Como já é do conhecimento geral, o Supremo Tribunal Federal[1] decidiu que, sob a perspectiva constitucional, é possível a devolução do ICMS pago adiantadamente no regime de substituição tributária, quando a base de cálculo efetiva da operação for inferior a presumida.

Segundo esse tribunal: “É devida a restituição da diferença do Imposto sobre Circulação de Mercadorias e Serviços – ICMS pago a mais no regime de substituição tributária para a frente se a base de cálculo efetiva da operação for inferior à presumida”.

Ainda foram modulados os efeitos do julgamento, para que esse julgamento sirva como orientação para todos os litígios judiciais pendentes submetidos à sistemática da repercussão geral e os casos futuros oriundos de antecipação do pagamento de fato gerador presumido realizada após a fixação do presente entendimento, “tendo em conta o necessário realinhamento das administrações fazendárias dos Estados membros e do sistema judicial como um todo decidido por essa Corte”.

Também foram julgadas improcedentes as ADIs 2.777 (proposta pelo Governador do Estado de São Paulo em face da Assembleia Legislativa do Estado de São Paulo) e 2.675 (proposta pelo Governador do Estado de Pernambuco em face da Assembleia Legislativa do Estado de Pernambuco).

Tal decisão é de grande relevância, uma vez que sempre houve interesse por parte das empresas que pretendiam se instalar em outros Estados (principalmente os respectivos Centros de Distribuição), em saber se, além de eventuais incentivos em relação ao ICMS, o Estado escolhido promovia, ou não, a devolução do ICMS retido antecipadamente, caso a operação fosse realizada em valores inferiores ao valor utilizado por presunção, para fins do cálculo do ICMS-ST. E nem poderia ser de outra forma, haja vista que esse regime de antecipação do pagamento do ICMS por substituição tributária tornou-se obrigatório para grande parte das mercadorias comercializadas.

Contudo, é importante analisar essa decisão com base em outro entendimento proferido por essa mesma Corte, citado, inclusive, no voto do Ministro Ricardo Lewandowski, qual seja, a ADI nº 1851 – AL.

Isto porque, o julgamento do RE nº 593.849-MG (sob análise), levou em consideração apenas a possibilidade de restituição de quantia cobrada a maior, nas hipóteses em que a operação final resultar em valores menores do que aqueles utilizados para efeito de incidência do ICMS.

Todavia, no acórdão decorrente da ADI 1.851/AL (Relator Ministro Ilmar Galvão), ao enfrentar a cláusula segunda do Convênio ICMS nº 13/97 (que determina a não restituição ou cobrança complementar do ICMS, quando a operação ou prestação subsequente à cobrança do imposto, sob a modalidade da substituição tributária, se realizar com valor inferior ou superior àquele com base no artigo 8º, da Lei Complementar nº 87/96), ficou estabelecido que “O fato gerador presumido, por isso mesmo, não é provisório, mas definitivo, não dando ensejo a restituição ou complementação do imposto pago, senão, no primeiro caso, na hipótese de sua não-realização final. Admitir o contrário valeria por despojar-se o instituto das vantagens que determinaram a sua concepção e adoção, como a redução, a um só tempo, da máquina-fiscal e da evasão fiscal a dimensões mínimas, propiciando, portanto, maior comodidade, economia, eficiência e celeridade às atividades de tributação e arrecadação”.

No voto proferido pelo Ministro Ricardo Lewandowski, ele mesmo destacou que a decisão proferida pelo Plenário na ADI 1.851 não constituiria, segundo seu entendimento, óbice à adequada solução da questão sob exame.

Vamos aprofundar um pouco mais esse entendimento.

A ADI nº 1.851/AL foi proposta contra a já citada cláusula segunda, do Convênio ICMS nº 13/97 (bem como em relação ao Decreto do Estado de Alagoas). Assim estabelece a citada cláusula segunda:

“Cláusula segunda: Não caberá a restituição ou cobrança complementar do ICMS quando a operação ou prestação subsequente à cobrança do imposto, sob a modalidade da substituição tributária, se realizar com valor inferior ou superior àquele estabelecido com base no artigo 8º da Lei Complementar 87, de 13 de setembro de 1996”.

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Segundo o voto do Ministro Ilmar Galvão (relator da ADI), uma das finalidades do citado Convênio era prevenir mais uma guerra fiscal entre os Estados, evitando a concessão de benefício tributário representado pela restituição do ICMS cobrado a maior em razão da base de cálculo presumida ser superior ao valor real da operação de saída.

Ainda segundo seu entendimento o fato gerador do ICMS e respectiva base de cálculo, dentro do regime de substituição tributária, apesar de presumidos, não tem caráter provisório, devendo ser considerados definitivos (salvo na hipótese de não se realizar o fato gerador presumido).

Nessa linha de raciocínio, não há que se falar em tributo para a maior, ou a menor, em decorrência do preço pago pelo consumidor final, para fins de compensação ou ressarcimento, seja por parte da Fazenda Estadual, seja por parte do contribuinte substituído, não sendo crível admitir que o legislador pudesse criar mecanismos com o intuito de inviabilizar a utilização de compensação de eventuais excessos ou faltas, em face do valor real da última operação.

O plenário, após vários manifestação de seus Ministros, reputou como constitucional a não restituição ou cobrança complementar do ICMS quando a operação ou prestação subsequente à cobrança do imposto, sob a modalidade da substituição tributária.

Tal entendimento, contudo, a nosso ver, encontra-se superado em face do acórdão proferido no RE nº 593.849-MG, em sede de Repercussão Geral, que, apesar de somente se referir pela restituição da diferença do ICMS pago a maior no regime de substituição tributária, quando verificado que a base de cálculo efetiva for inferior a presumida, certamente afetou a conclusão a ser obtida em situações onde a base de cálculo presumida foi inferior à efetivamente praticada.

Tanto na ADI nº 2.777, quanto na ADI nº 2675, além da própria decisão sob análise, o objeto era a possibilidade de devolução da parcela retida a maior, quando configurada a utilização de uma base de cálculo presumida em valor superior ao da efetiva operação realizada.

Mas, como fica a situação contrária, ou seja, quando a base de cálculo efetiva for SUPERIOR à presumida?

Não se pode desconsiderar o entendimento já proferido pelo STF (ADI 1.851/AL), onde expressamente reconheceu a constitucionalidade da cláusula segunda do Convênio ICMS nº 13/97 e, nesse sentido, a constitucionalidade daquela norma, no sentido de não se exigir a cobrança complementar do ICMS, quando a operação ou prestação se realizar com valor superior ao da base de cálculo presumida.

Mas, como já citado anteriormente, houve nítida mudança de entendimento do STF, no sentido de que a base de cálculo presumida deixa de ser definitiva (ADI nº 1.851), passando a ter um nítido caráter provisório (RE nº 593849 RG / MG), de forma diametralmente oposta do que esse Tribunal entendeu no passado.

Ou seja, pelo atual entendimento do STF é possível concluir (ainda que não expressamente mencionado), que o fato gerador presumido é provisório, a ensejar a possibilidade dos Estados em exigir o complemento do ICMS, caso a base de cálculo presumida seja inferior àquela efetivamente praticada.

A nosso ver nem poderia ser de outra forma, haja vista que se a finalidade da antecipação do ICMS por substituição tributária é, além de facilitar a fiscalização, antecipar o pagamento do imposto estadual que ocorreria nas demais etapas comerciais até ao consumidor final, não há como se pretender que eventuais diferenças (para maior, ou menor), não sejam levadas em consideração, a fim de que a norma atinja sua finalidade plena, ou seja, apenas a tributação sobre a correta base de cálculo adotada na operação com o consumidor final.

Admitir hipótese contrária é permitir o enriquecimento ilícito do Estado (o que foi afastado pelo STF), ou a ausência de pagamento do ICMS por parte do contribuinte, seja porque haverá uma tributação que não corresponde a uma operação de circulação de mercadorias, seja pelo não pagamento total do ICMS devido nessa operação, em nítida afronta à própria hipótese de incidência do ICMS.

Certamente, o que não se poderá admitir é a edição de legislações infraconstitucionais que, sob o manto de restituir o ICMS cobrado a maior, criem exigências de obrigações acessórias que, ao final, por sua complexidade, acabem por retirar de restituição constitucionalmente garantido e ratificado pelo STF.

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